Employees working with hazardous materials in the U.S. often need specific training to meet regulatory requirements. Different agencies enforce these requirements based on the type of work being performed. The Pipeline and Hazardous Materials Safety Administration (PHMSA), under the Department of Transportation (DOT), oversees hazardous materials transportation. The Occupational Safety and Health Administration (OSHA), under the Department of Labor (DOL), regulates general operations, emergency response, and waste clean-up. The Environmental Protection Agency (EPA) manages hazardous waste management and disposal.
This article outlines the training requirements, frequency, and applicability for each area.
Hazmat Transportation Training
Hazmat training is mandatory for all personnel involved in the safe transport of hazardous materials. This includes anyone who:
- Reads and interprets regulations;
- Supervises hazmat shipping operations;
- Classifies or names hazardous materials for transport;
- Packages shipments or loads trailers/containers;
- Places hazmat marks and labels on shipments;
- Loads or unloads vehicles;
- Prepares or signs hazmat shipping papers;
- Delivers packages; or
- Trains crews to handle hazardous materials.
Training Requirements:
DOT regulations (49 CFR 172.704) require hazmat training to cover five key topics:
1. General hazmat awareness;
2. Function-specific hazmat training;
3. Hazmat security awareness;
4. Hazmat safety training; and
5. Hazmat security plan training (if applicable).
New hires must complete training within 90 days of employment and work under supervision until trained. Refresher training is required every three years.
International Shipments:
For international transport, additional training required:
- IATA Dangerous Goods Regulations for air transport (renewed every two years).
- IMDG Code for vessel transport (renewed every three years).
General Hazmat Operations Training
General hazmat operations fall under OSHA and include two main areas: Hazard Communication (HAZCOM) and Hazardous Waste Operations and Emergency Response (HAZWOPER).
OSHA Hazard Communication (HAZCOM)
HAZCOM training is required for employees who work with or may be exposed to hazardous chemicals. It teaches employees to recognize hazard labels and use Safety Data Sheets (SDS) to protect themselves and others.
- Training Frequency: Required within six months of employment and repeated annually.
- Regulatory Reference: 29 CFR 1910.1200.
OSHA HAZWOPER
HAZWOPER training protects personnel involved in emergency response or clean-up of hazardous substances, including EPA hazardous wastes, CERCLA hazardous substances, DOT hazardous materials, and biologic agents.
Who Needs HAZWOPER Training?
1. Clean-up Site Workers: Personnel involved in hazardous substance or waste clean-up (e.g., EPA Superfund sites).
2. TSDF Workers: Employees at hazardous waste treatment, storage, and disposal facilities.
3. Emergency Responders: Employees who respond to hazardous substance emergencies, including facility employees and firefighters.
Emergency Responder Levels:
1. Level 1 - Awareness Level: Employees who identify emergencies and alert others.
2. Level 2 - Operations Level: Employees who respond defensively to contain spills.
3. Level 3 - HAZMAT Technician: Employees who respond offensively to stop releases.
4. Level 4 - HAZMAT Specialist: Employees who support technicians and liaise with authorities.
5. Level 5 - On-Scene Incident Commander: Employees who manage the incident scene.
Training Requirements:
- Initial training: Minimum of 24 hours.
- Refresher training: 8 hours annually, plus hands-on/field training as needed.
EPA RCRA Hazardous Waste Training The EPA requires hazardous waste training for all personnel whose actions could lead to noncompliance with Resource Conservation and Recovery Act (RCRA) regulations.
Typical Responsibilities for Hazardous Waste Personnel:
- Identifying or counting hazardous waste;
- Choosing containers;
- Marking or labeling containers;
- Handling or moving waste;
- Inspecting containers;
- Operating waste-generating processes;
- Managing waste in satellite areas; and
- Applying federal or state hazardous waste regulations.
Training Requirements by Generator Category:
1. Large Quantity Generator (LQG): Generates over 1,000 kg (2,200 lbs) of hazardous waste or over 1 kg (2.2 lbs) of acutely hazardous waste monthly. Annual RCRA refresher training is required.
2. Small Quantity Generator (SQG): Generates less than 1,000 kg of hazardous waste and 1 kg or less of acutely hazardous waste monthly. Annual training is a best practice.
3. Very Small Quantity Generator (VSQG): Generates 100 kg or less of hazardous waste monthly. No specific training is required, but employees should understand regulations.
FAQ Section
1. What training do you need to ship hazardous materials?
You need hazmat transportation training, which covers general awareness, function-specific tasks, security awareness, safety training, and security plan training (if applicable).
2. How much does hazmat training cost?
Costs vary depending on the provider and type of training. Online courses may range from $50 to $300, while in-person training can cost more.
3. How do I get hazardous material certification?
Complete the required training through a certified provider, pass any assessments, and maintain your certification with periodic refresher training.
4. Does OSHA require hazmat training?
Yes, OSHA requires HAZCOM and HAZWOPER training for employees working with hazardous chemicals or involved in emergency response and waste clean-up.
5. How hard is HazMat training?
The difficulty depends on the type of training and your background. Basic awareness training is straightforward, while advanced HAZWOPER or technical training may require more effort and hands-on practice.
For further clarification on hazardous materials training requirements, consult a safety professional or regulatory expert. Proper training ensures compliance and protects both employees and the environment.
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